HomeMy WebLinkAbout99-042640
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Of PLNNSTLVANIA
JUDICIAL DISTRICT
NOTICE OF APPEAL
DISTRICT JUSTICE JUDGMENT
FROM
COMMON PLEAS Nm 9 Y - tf / Y
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
dale and in the case mentioned below
Cv 19 LWDU 2 1
IT 19
ma owk win be signed ONLY when this natation is required under Pa R.CPJP. No ` 7( appellant was CLAIMANT (see Pa. R.C.P.J.P. No.
1008&
This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST
SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within twenty (20) days after
Signature of Prothonotary or Deputy tiling his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothoratary
Enter rule upon , appellee(s), to file a complaint in this appeal
Name of appellee(s) (Common Pleas No ) within twenty (20) days after service of rule or suffer entry of judgment of ran pros
Signvrwe of appellmrt or his attorney or agent
RULE: To , appellee(s).
Nerve of appe/ace(s)
(1) You one ratified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
service of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST OU.
(3) The date of service of this rule if service was by mail is the date of mailing
Dale: 17-13 19
span.e a a De"
AOPC 312-01
COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
; as
AFFIDAVIT: I hereby swear or affirm that I served
? a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice designated therein on
(date of service) , 19_, ? by personal service ? by (certified) (registered) mail, sender's
receipt attached hereto, and upon the appellee, (name) on
19? by personal service ? by (certified) (registered) mail, sender's receipt attached hereto.
? and furtherthat l servedthe Rule to File a Complaint accompanying the above Notice of Appeal upon theappellee(s) towhom
the Rule was addressed on 19- ? by personal service ? by (certified) (registered)
mail, sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF , 19-
Signature or official before whom affidavit was made
Title of official
My commission expires on
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Signature of allianf
, COMMONWEALTH OF PENNSYLVANIA
No,
VULWZ UaAXL)
09-3-03
DJ Name: Hon.
SUSAN R. DAY
Admeae: 229 MILL STREET, BOX 167
MT. HOLLY SPRINGS, PA
Teiooone: (717) 486.7672 17065
ATTORNEY FOR PLAINTIFF :
CAROL LINDSAY, ESQ.
11 E. HIGH ST.
CARLISLE, PA 17013
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF: CIVIL CASE
rROSS, MICHAEL NAME and ADDRESS
-1
44 OAR PARR AVE.
CARLISLE, PA 17013
L J
VS.
DEFENDANT: NAMEand ADDRESS
[RR. & MRS. MANUEL D. GOMEZ
169 LEHMAN DRIVE
YORK, PA 17403
L J
DocketNo.: CV-0000021-
Date Filed: 2/10/99
CROSS COMPLAINT 001
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR DEFENDANT
Q Judgment was entered for: (Name) mg- s Mag MnNUET n GOM Z
® Judgment was entered against: (Name) _ ROSS MICHAEL
in the amount of $ on on:
F1 Defendants are jointly and severally liable.
? Damages will be assessed on:
This case dismissed without prejudice.
? Amount of Judgment Subject to
Attachment/Act 5 of 1996 $
Levy is stayed for days or ? generally stayed.
D Objection to levy has been filed and hearing will be held:
Date: Place:
Time:
ANY PARTY HAS THE RIGHT TO
OF APPEAL WITH THE PROTH
MUST INCLUDE A COPY OF T I;
Date/
I .certify that this isXfrueAnd 1
WITHIN 30 DAYS AFTER
'LERK OF THE COURT
10FJUDGMENTC yyg54
of the
(Date of Judgment) - S/r F/qq
(Date & Time)
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits $
Post Judgment Costs $
------------
Certified Judgment Total $
ENTRY OF JUDGMENT BY FILING A NOTICE
)MMON PLEAS, CIVIL DIVISION. YOU
FORM WITH YOUR NOTICE OF APPEAL.
District Justice
edings containing the judgment.
, District Justice
My commission exdi'res first Monday of January, )-'2004 SEAL
AOPC 315-99
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JUL 101999
COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the
date and in the case mentioned below:
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rlao Ms of l APPEUAW C ( '?
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GATE N rK Cr,)5E of (ftanr) f0of
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Ihis block will be signed ONLY when this notation is required under Pa R.C.P.J.P. Na
1008&
This Notice of Appeal, when received by the District Justice, will operate as a
SUPERSEDEAS to the judgment for possession in this case
PRAECIP,E TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (;ee Pa. R.C.P.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee). ""
PRAECIPE: To Prothonotary
Enter rule upon , appellee(s), to file a complaint in this opped
Name of appellee(sl
(Common Pleas No.
) within twenty (20) days after service of rub or suffer entry of judgment of non pros.
NOTICE OF APPEAL
FROM
9P-ya6V
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS Na
If appellant was CLAIMANT (see Pa. R.C.P.J.P. No.
1001(6) in action before District Justice, he MUST
FILE A COMPLAINT within twenty (20) days alter
filing his NOTICE of APPEAL.
9gnatwo of appollml or ha affair" or a"
RULE: To
appeAWS)
appellee(s).
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
service of this role upon you by personal service or by certified or registered maiL
(2) R you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST YOU.
(3) The dale of service of this rule if service was by mail is the date of mailing.
Dole: , 19_.
S~ of Hpthonasy, or DA"
AOPC 31291
COURT FILE
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
: as
AFFIDAVIT: I hereby swear or affirm that I served
99-4264
21a copy of the Notice of Appeal, Common Pleas No. . , upon the District Justice designated therein on
(date of service) 7/21 1999 ? by personal service ® by (certified) (registered) mail, sender's
receipt attached hereto, and upon the appellee, (name) Manuel D. Gomez, cat! certified)
on
7'%1 , 19 99? by personal service ?'by (certified) (registered) mail, sender's receipt attached hereto.
? and further that l served the Rule to Filea Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom
the Rule was addressed on , 19- ? by personal service ? by (certified) (registered)
mail, sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS "- ? DAY OF -`^?^•6. , 19.GL
- 674-0
S gnaru/ re or-official before wh et idaw OS made
Title of official TERESA BUF4010LDEfl ?„ry pypllc
CuYM, cwrDedano f:oratly, PA
My commission xp19
Signature of afflant
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not use for International Mail fSee reverse)
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Postage $ 3
Certified Fee !
Special Delivery Fee
Resincted Delivery Fee
Actium Recaol Showing to 1
Whom S Dale Delivered
Rehm Receipt Showing m Mcm,
Date, A Addressee s Address
TOTAL Postage A Fees S r:?
Postmark or Date
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US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do nor use for International Mail (See reverse)
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Pgsl ice, 5lale.ajlade 7? ?_
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Postage $ .33
Certified Fee
Special Delivery Fee
Restricted Delivery Fee
Retum Receipt Showing to
Whom d Dale DeSvered qq
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Realm P s e Ad to Yaiaa
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TOTAL Postage a Fees S.
Postmark or Date
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u-K.
ross notice to plead July 29, 1999
MICHAEL ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in
the following pages, you must take action within thirty (30) days after this Complaint and notice a:e
served by entering a written appearance personally or by attomey and filing in writing with the Court
your defenses or objections to the claims set forth against you. You are wamed that if you fail to do
so, the case may proceed without you and a judgment may be entered against you by the Court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
ID#41693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
ross Complaint July 29, 1999
MICHAEL ROSS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
MANUEL D. GOMEZ, ET UX,
Defendant
CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
COMPLAINT
NOW comes MICHAEL ROSS, by and through his counsel, Flower, Flower & Lindsay,
P.C., and states as follows:
1. Plaintiff is an adult individual who resides at 44 Oak Park Avenue, Carlisle,
Cumberland County, Pennsylvania.
2. Defendants are adult individuals who reside at 169 Lehman Drive, York, York
County, Pennsylvania.
3. On December 4, 1998, at the special insistence of Defendants, Plaintiff picked up a
1983 G.M.C. C-1500 pick up truck for transport to his garage to undertake repairs specifically
requested by the Defendant.
4. Repairs to the truck were undertaken by Plaintiff on a time and materials basis with
Plaintiffs time valued at $30.00 per hour.
5. On December 20, 1998, Defendants demanded a return of the vehicle.
6. Plaintiff had expenses totaling $122.22 for parts for Defendants' vehicle.
7. Defendants damaged Plaintiffs adjustable timing light which had to be replaced at a
cost of $95.35.
8. Plaintiff expended 9.7 hours on the repairs to Defendants' vehicle for a total labor
cost of $513.17.
ross Complaint July 29, 1999
MICHAEL ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant
COMPLAINT
NOW comes MICHAEL ROSS, by and through his counsel, Flower, Flower & Lindsay,
P.C., and states as follows:
1. Plaintiff is an adult individual who resides at 44 Oak Park Avenue, Carlisle,
Cumberland County, Pennsylvania.
2. Defendants are adult individuals who reside at 169 Lehman Drive, York, York
County, Pennsylvania.
3. On December 4, 1998, at the special insistence of Defendants, Plaintiff picked up a
1983 G.M.C. C-1500 pick up truck for transport to his garage to undertake repairs specifically
requested by the Defendant.
4. Repairs to the truck were undertaken by Plaintiff on a time and materials basis with
Plaintiffs time valued at $30.00 per hour.
5. On December 20, 1998, Defendants demanded a return of the vehicle.
6. Plaintiff had expenses totaling $122.22 for parts for Defendants' vehicle.
7. Defendants damaged Plaintiffs adjustable timing light which had to be replaced at a
cost of $95.35.
8. Plaintiff expended 9.7 hours on the repairs to Defendants' vehicle for a total labor
cost of $513.17.
ross Complaint July 29, 1999
9. The total damages claimed by Plaintiff is $513.17
WHEREFORE, Petitioner prays this Honorable Court to enter a judgment against
Defendants in the amount of $473.22 with costs.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By
Car I J. Lindsay, E`99 ire
CIE4 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
Toss Complaint July29,1999
MICHAEL ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant
CERTIFICATE OF SERVICE
AND now, this 30 day of 1999, I, Carol J.
Lindsay, Esquire, of the law firm of FLOWER, FLO & LINDSAY, P.C., Attorneys, hereby certify
that I served the within Complaint this day by depositing same in the United States Mail, First Class,
Postage Prepaid, in Carlisle, Pennsylvania, addressed to:
Mr. and Mrs. Manuel D. Gomez
169 Lehman Drive
York, PA 17403
FLOWER, FLOWER & LINDSAY
Attorneys for Plaintiff
By -?_
arol J. Lindsay, Esquire
ID # 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904,
relating to unsworn falsification to authorities.
2 t'- ?t V '?Z-ro
Michael Ross
Date: 2 Q2 3- _7
MICHAEL ROSS
V.
MR. & MRS. MANUEL D. GOMEZ
IN THE COURT OF COMN 70N PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
NO. 1999 - 4264 CIVIL TERM
ORDER OF COURT
AND NOW, to wit, this I t day of August, 1999, on consideration
of the attached petition, the Rule is made absolute, and the appeal stricken.
By the Court,
Edgar B Bayley, J.
.l
. ?' . t'(
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?:.i i J;.
?h
?,:.':.
MICHAEL ROSS IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
V. CIVIL ACTION - LAW
MR. & MRS. MANUEL D. GOMEZ : NO. 1999 - 4264 CIVIL TERM
PETITION TO MAKE RULE ABSOLUTE
The rule to show cause why the petition should not be granted and the
appeal stricken was signed by The Honorable Edgar B. Bayley on August 9, 1999.
The Prothonotary sent the rule to show cause to Carol J. Lindsay, Esquire,
Counsel for Michael Ross, by first class mail. A copy of the petition and Rule to
Show Cause are attached hereto.
No objection to the proposed striking of the appeal has been filed.
WHEREFORE, it is prayed that the Court make the rule absolute.
Respectfully submitted,
DOUGLAS, DOUGLAS & DOUGLAS
By??u 11
Geo a F. Dogl las, III, Esquire
Attorney for Counterdefendants
Atty. I.D. # 61886
27 West High Street
Carlisle, PA 1701-1
717-243-1790
MICHAEL ROSS IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
V. CIVIL ACTION - LAW
MR. & MRS. MANUEL D. GOMEZ : NO. 1999 - 4264 CIVIL TERM
RULE TO SHOW CAUSE
AND NOW, this ?-) day of August, 1999, upon consideration of the
within petition, a RULE is hereby entered on the plaintiff, Michael Ross, through
his counsel, Carol J. Lindsay, Esquire, to show cause why the petition should not
be granted, and the appeal stricken.
Rule returnable _0 days from date of service. (?'oic71O?h /
4,11 c2 e ? A h u ?U?r ? C1?e ? Q cv ?u! ?i` c Ctc(? "6 C, /,-,W-r*, Yc ?iS?JJ. (?
J By the Court,
Gc.
J.
Carol J. Lindsay, Esquire
Flower, Flower & Lindsay
11 East High Street
Carlisle, PA 17013
For Counterplaintiff
George F. Douglas, III, Esquire
Douglas, Douglas & Douglas
27 West High Street
Carlisle, PA 17013
For Counterdefendants
-?1 - . -..-V F7f ?M PECORD
rC rr,ta s>.t my hand
and a "-I Gi sail Court at Carlisio, Pa.
This ........ .. day of...... L ...... 19... 2.cl
.
................ ?.. ??...... e .......
Z& Prothonotary
MICHAEL ROSS
V.
MR. & MRS. MANUEL D. GOMEZ
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION- LAW
NO. 1999 - 4264 CIVIL TERM
PETITION TO STRIKE APPEAI UNTIMELY FILED
Petitioners, Mr. and Mrs. Manuel D. Gomez, by the undersigned counsel,
George F. Douglas, III, Esquire, hereby petition to strike the appeal untimely
filed, and, in support thereof, represents as follows:
1. A judgment was entered for defendants, Mr. and Mrs. Manuel D.
Gomez, and against plaintiff, Michael Ross, in his counterclaim, on May 15, 1999.
A copy of the entry of judgment is attached hereto.
2. Counsel for Michael Ross filed an appeal on July 13, 1999. A copy
is attached hereto.
3. The petitioners received notice of the appeal by certified mail from
counsel for Michael Ross postmarked July 21, 1999. A copy of the letter and
envelope are attached hereto.
4. The appeal was not filed within thirty (30) days of the entry of
judgment, as provided in Pa. R.C.P. 1002, and should not have been accepted by
the Prothonotary's Office as a timely filing.
WHEREFORE, your petitioners respectfully request that this Court enter
an Order striking the appeal filed in this matter.
Respectfully submitted,
Dated: August 6,1999
DOUGLAS, DOUGLAS & DOUGLAS
George F. Douglas, III, Esquire
Attorney for Petitioners
Atty. I.D. # 61886
27 West High Street
P.O. Box 261
Carlisle, PA 17013
717-243-1790
MICHAEL ROSS
V.
MR. & MRS. MANUEL D. GOMEZ
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
NO. 1999 - 4264 CIVIL TERM
VERIFICATION
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
This verification is made pursuant to Pa. R.C.P. 1024(c) by counsel for Mr.
and Mrs. Manuel D. Gomez, based upon information received.
To the best of signer's knowledge, information, and belief, the foregoing is
true and correct.
DOUGLAS, DOUGLAS & DOUGLAS
Dated: August 6, 1999 George F. Douglas, III
?i UULINI Y Uh: wV&bAX ,*.LW
. IF?,.rp Obt Na:
09-3-03
a Nm : eqn
SUSAN K. DAY
Ad'-; 229 MILL STRZET, BOX 167
MT. HOLLY SPRINGS, PA
nrwn-: (717) 486-7672 17065
ATTORNEY FOR PLAINTIFF :
CAROL LINDSAY, ESQ.
11 E. HIGH ST.
CARLISLE, PA 17013
,°v < aver v, V V L4i/Y1GJ\ l l tl ?"7Mdtl:'(r}jt d7?'
PLAINTIFF: CIVIC CASE
LOSS, MICHAEL NAME "ADDRESS
44 OAR PARK AVE.
CARLISLE, PA 17013
L VS. J
DEFENDANT: NAME W ADDRESS
ria- & MRS. MANUEL D. GOMEZ 'I
169 LEHMAN DRIVE
YORK, PA 17403
L J
'DocketNo.: CV-0000021-99.
Date Filed: 2/10/99
CROSS COMPLAINT 001
THIS IS TO NOTIFY YOU THAT:
Judgment: MR DEIVIDMA
*fT
E XI Judgment was entered for: (Name)
® Judgment was entered against: (Name) _gngg. m7cmnur,
in the amount of $ nn on:
Defendants are jointly and severally liable.
L_.I Damages will be assessed on:
f7 This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/Act 5 of 1996 $
? Levy is stayed for days or ? generally stayed.
F1 Objection to levy has been filed and hearing will be held:
Date:
Time:
Place:
ANY PARTY HAS THE RIGHT TO AP AL WITHIN 30 DAYS AFTER
OF APPEAL WITH THE PROTH OTAR CLERK OF THE COURT
MUST INCLUDE A COPY OF IS N F JUDGMEN`7
Date
1 certify that this is a nd pybf the re e'pi
ate
7L A/
My commission ex es first Monday of January, 2004
(Date of Judgment) r/i q/ua
(Date & Time)
Amount of Judgment $ .0
0
Judgment Costs $ .0
0
Interest on Judgment $ .00
Attorney Fees $ .00.
Total $ .0 i
i
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $ i
T E'eNTRY OF JUDGMENT BY FILING A NOTICE
OMMON PLEAS, CIVIL DIVISION. YOU
aIP FORM WITH YOUR NOTICE OF APPEAL.
District Justice
ceedings containing the judgment
, District Justice
SEAL
AOPC 315.99
APIPICIAL DWRICT FROM
i
DISTRICT JUSTICE JUDGMENT
i
COMMpN P"S Pao I 7 - L/_
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal fnxn the judgment randemd by the District Justice an the
daft and in the case mentioned behm
z ,cam ei ss .---1?- 3-
Cit 19-aQaa42 z r -gy
LT 19
100811, ra R jr. m )appellant was CLAIMANT (See ft R.CF.J.P. No.
This Notice of Appeal, when received by the District Justice, "it operate as a i 1001(6) in action before Distict Justice, he MUST
SUPERSEDEAS to the judgment for possession in this cos. FILE A COMPLAINT wllflin
twenty (20) days after
ov? or Protlnoruotary or Deputy filing his NOTICE of APPEAL.
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This sectbn of b7n to be used ONLY when appellant was DEFENDANT (see Pa R.C.P.J.P. No. 1001(7) in action before Dstnot Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prethanotmy
Enter rule upon
nmrrre a appedeetsl ' aPPdlee(s)' to file a cortiplont in this upped
(Commonn Pleas No
) within twenty (20) days after service of rub or suffer entry of judgment of non pros
RULES To W61110 Of aaoeaes a use atamey a agars
Nang or apperlee(sl ' aPP?ee(s?
(1) You an notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the dote of
service of ft rule upon you by personal service or by certified a registered mm1
(2) N you do not fie a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST U.
(3) The data of service of fhis rule i service was by marl is the dak of mailing.
Daft: 7 /-3 , 19,•
Slpruuva of noray a Oaouty
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ACPC: altar
LAN OFFICES
FI.OWEIt, FZOWER & LINDSAY
A PROFPyto. LCOMAAno,
11 PAST HIGH STRM
i ? 1)?TU C'P`uSLE. PENN- SYLVANIA 17013-3016
'. ?1- LINDSAY
July 16, 1999
CERTIFIED MAR R I r ro?,
Mr. and Mrs. Manuel D. Gomez ycrrT
169 Lehman Drive
York, PA 17403
RE: Ross Y. Gomez
Dear Mr, and Mrs. Gomez:
(71n xe3.fSu
PA FL ,?
behalf. I enclose for service a copy of the Notice of Appeal which I filed on Mr. Ross's
Very truly yours,
CJLtt)b
FLOWER, FLOWER & LINDSAY, P.C.
Carol J.
ee: Lhsttxt JUSWA Susan K. 0" . CleL Ltu rvrena)
229 Mil Street, got 167. UL movy SXw.0j
Michael Ross (wtew) -
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YOU ARE HEREBY REOUIRED TO FILE A
WRITTEN RESPONSE TO THE ENCLOSED
WITHIN TWENTY IE01 DAYS FROM SERVICE
HEREOF OR A JUDGMENT MAY BE
ENTERED AGAINST YOU,
BY -'
ATTORNEY
DOUGLAS. DOUGLAS & DOUGLAS
ATTORNEYS AT LAW
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CARLISLE, PCFIHSYLVAIIIA
nou ozm
WE DO MCRFRY CERTIFY THAT THE
WITHIN 15 A TRUE AND CORRECT COPY
OF THE ORIGINAL FILED IN THIS
ACTION.
ATTORNEY
MICHAEL ROSS : IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PA
V. : CIVIL ACTION - LAW
MR. & MRS. MANUEL D. GOMEZ : NO. 1999 - 4264 CIVIL TERM
RULE TO SHOW CAUSE
AND NOW, this day of August, 1999, upon consideration of the
within petition, a RULE is hlebyy entered on the plaintiff, Michael Ross, through
his counsel, Carol J. Lindsay, Esquire, to show cause why the petition should not
be granted, and the appeal stricken.
C ? w?-
Carol J. Lindsay, Esquire
Flower, Flower & Lindsay
11 East High Street
Carlisle, PA 17013
For Counterplaintiff
George F. Douglas, III, Esquire
Douglas, Douglas & Douglas
27 West High Street
Carlisle, PA 17013
For Counterdefendants
Rule returnable 10 days from date of service. \?c wLb1 "j?+4.4' S 6jk
. : r : i
-
il:
MICHAEL ROSS
V.
MR. & MRS. MANUEL D. GOMEZ
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
NO. 1999 - 4264 CIVIL TERM
PETITION TO STRIKE APPEAL UNTIMELY FILED
Petitioners, Mr. and Mrs. Manuel D. Gomez, by the undersigned counsel,
George F. Douglas, III, Esquire, hereby petition to strike the appeal untimely
filed, and, in support thereof, represents as follows:
1. A judgment was entered for defendants, Mr. and Mrs. Manuel D.
Gomez, and against plaintiff, Michael Ross, in his counterclaim, on May 15,1999.
A copy of the entry of judgment is attached hereto.
2. Counsel for Michael Ross filed an appeal on July 13,1999. A copy
is attached hereto. '
3. The petitioners received notice of the appeal by certified mail from
counsel for Michael Ross postmarked July 21, 1999. A copy of the letter and
envelope are attached hereto.
4. The appeal was not filed within thirty (30) days of the entry of
judgment, as provided in Pa. R.C.P. 1002, and should not have been accepted by
the Prothonotary's Office as a timely filing.
WHEREFORE, your petitioners respectfully request that this Court enter
an Order striking the appeal filed in this matter.
Respectfully submitted,
Dated: August 6,1999
DOUGLAS, DOUGLAS & DOUGLAS
Byj-
George F. Douglas, III, Esquire
Attorney for Petitioners
Atty. I.D. # 61886
27 West High Street
P.O. Box 261
Carlisle, PA 17013
717-243-1790
MICHAEL ROSS
V.
MR. & MRS. MANUEL D. GOMEZ
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CIVIL ACTION - LAW
NO. 1999 - 4264 CIVIL TERM
VERIFICATION
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
This verification is made pursuant to Pa. R.C.P. 1024(c) by counsel for Mr.
and Mrs. Manuel D. Gomez, based upon information received.
To the best of signer's knowledge, information, and belief, the foregoing is
true and correct.
DOUGLAS, DOUGLAS & DOUGLAS
By (AA
Dated: August 6,1999 George F. Douglas, I
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND NOTICE OF JUDGNIENTITRANSCRIPT
MAo'aei. NO.. PLAINTIFF: CIVIL CASE
•
09-3-03 I
rROSS, MICHAEL NAME ,m ADDRESS
0.1 NUne. ran
SUSAN K. DAY 44 OAR PARR AVE.
A0°
"°' 229 MILL STREET, SOX 167 CARLISLE, PA 17013
MT. HOLLY SPRINGS, PA L. J
VS.
T,M,hom:(717) 486-7672 17065 DEFENDANT: NAME WADDRESS
rMR. & MRS. MANUEL D. GOMEZ
1
ATTORNEY FOR PLAINTIFF 169 LEHMAN DRIVE
YORK, PA 17403
CAROL LINDSAY, ESQ. L J
11 E. HIGH ST. Docket No
: CV-0000021-99
CARLISLE, PA 17013 .
Date Filed: 2110199
CROSS COMPLAINT 001
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR n SFEND ram
® Judgment was entered for: (Name) wag - s lace ernra•+?r n r^t r°7
® Judgment was entered against: (Name) _ Rnss . KI RAgT,
in the amount of $ _nn on: (Date of Judgment) C; 41
a?gg
Defendants are jointly and severally liable. (Date & Time)
7 Damages will be assessed on:
0 This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/Act 5 of 1996 $
Levy is stayed for days or ? generally stayed.
0 Objection to levy has been filed and hearing will be held:
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
Post Judgment Credits $
Post Judgment Costs $
------------
Certified Judgment Total $
Date: Place:
Time
ANY PARTY HAS THE RIGHT TO
OF APPEAL WITH THE PROTH
MUST INCLUDE A COPY OFT I:
Date/
[.Certify that this is
WITHIN 30 DAYS AFTER
'LERK OF THE COURT,(
the
My commission expVres first Monday of January,
i
04
ENTRY OF JUDGMENT BY FILING A NOTICE
IMMON PLEAS, CIVIL DIVISION. YOU
FORM WITH YOUR NOTICE OF APPEAL.
District Justice
tidings containing the judgment.
, District Justice
SEAL
AOPC 315.99
COMMONWEALTH Of PENNSYLVANIA
COURT OF COMMON ?UAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
Notice is gran that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice an the
date and in the me mentioned below
cb sS p _ _?;3 =p
ATE
(?? (?rLL??S ?m2_ ? r 7nr-3
CV 19 M0,069 z I -gy
IT 19
186 . - w ? W,NL, ?-., 113 nomncn is requvea urwer ra K!.rJr. rva 1 appellant was CLAIMANT (see Pa. R.C.P.J.P. No.
00
This Notice of Appeal, when received by the District Justice, will operate as a 1001(6) in action before District Justice, he MUST
SUPERSEDEAS to the judgment for possession in this case FILE A COMPLAINT within
twenty (20) days a/item
or Deputy tiling his NOTICE of APPEAL.
igrwfae o1 fhanaary
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
COMMON PLEAS No Y 7 - e-1
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa. R.OP.J.P. No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Enter rule upon
appellearsl
appellee($). to file a complaint in this appeal
(Common Pleas Na
RULE: To , app?ee(s).
rixrie Of aAaellee(s)
SVW0`6 Of agoe9a d a his aaorney a ages
(1) You are nofified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of
service of this rule upon you by personal service or by certified or registered mar
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS WILL BE ENTERED AGAINST U.
(3) The date of service of this rule if service was by mail is the date of 7;L
Daft: 7-13 , 19?
Slgrreose a a Deputy
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
•aPC 312.84
LAW OFFICES
FLOWER. FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
11 EAST HIGH STREET
CARLISLE, PENNSYLVANIA 17013.3016
JAMES D. FLOWER
JAMES D A
J• LINDSAY
July 16, 1999
CERTIFIED MAIL: RETURN RECEIPT
Mr. and Mrs. Manuel D. Gomez
169 Lehman Drive
York, PA 17403
RE: Ross v. Gomez
Dear Mr. and Mrs. Gomez:
(717)2/5313
FA74 (717) 2434710
FFLe,qCjxokow
behalf. I enclose for service a copy of the Notice of Appeal which I filed on Mr. Ross's
Very truly yours,
FLOWER, FLOWER & LINDSAY, P.C.
Carol J. Ely
CJUtib
cc: Cutnct Justice Susan K. 00y - Opit U w rweTtct)
229 Mill Street, Box 167, ML HOIN SP(WdJS
Michael Ross (w/end)
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YOU ARE HEREBY REQUIRED TO FILE A
WRITTEN RESPONSE TO THE ENCLOSED DOUGLAS. DOUGLAS S DOUGLAS WE DD HEREBY CERTIFY THAT THE
WITHIN TWENtYlE01 DAYS FROM SERYIC[
HEREOF OR A JUDGMCNT MAY BE AiTOHNLYZAT LAW WITHIN IS A TRUE AND CORRECT COPY
ENTERED AGAINST YOU. Y .. mn...rn T., OF THE ORIGINAL FILED IN THIS
ACTION.
BY ATTORNEY - CARL17LE. PLNIbYLVANIA BY • _ AIJL1_9 tgq?1z`T
UOU-ONll ATTORNEY L
ross Complaint September 2, 1999
MICHAEL ROSS,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Vs. CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant/Respondent
ORDER OF COURT
AND NOW this
day of
1999, upon
consideration of the within Plaintiffs Petition to Strike Appeal Untimely Filed and Counter-
Claim and Petition to Allow the Appeal Nunc Pro Tunc, Petition to Strike Appeal is dismissed.
By the Court,
MICHAEL ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant/Respondent
PLAINTIFF'S PETITION TO STRIKE
APPEAL UNTIMELY FILED
NOW comes MICHAEL ROSS, by and through his counsel, Flower, Flower & Lindsay,
P.C., and answers the Rule to Show Cause entered by the Court on August 9, 1999, as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Denied. By way of further answer, although the District Justice entered judgment
on May 15, 1999 as set out on the exhibit attached to the Petition, Notice of the judgment
transcript form was not sent by the District Justice's office until July 8, 1999 as noted on the Entry
of Judgment.
WHEREFORE, Petitioner prays this Honorable Court to Dismiss the Petition to Strike the
Appeal.
COUNTER-CLAIM AND
PETITION TO ALLOW THE APPEAL
NUNC PRO TUNC
5. Although the Judgment in the captioned case was entered on May 15, 1999, Notice
of the Judgment was not sent until July 8, 1999, on the specific request of counsel for the Plaintiff.
6. Rule 1002 of the Rules of Civil Procedure for District Justice's requires a Notice of
Judgment to be filed with an Appeal.
ross Complaint September 2, 1999
7. No Notice of Judgment was issued by the District Justice until July 9, 1999.
8. A Court may permit an Appeal Nunc Pro Tunc upon a showing of an error in the
judicial system.
9. The failure of the District Justice to mail the Notice of Judgment is such an error.
WHEREFORE, Plaintiff prays this Honorable Court to permit the Appeal Nunc Pro Tunc.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
ID# 4`, ?, ,,
11 East High Street
Carlisle, PA 17013
(717) 243-5513
ross Complaint September 2, 1999
VERIFICATION
The undersigned, Carol J. Lindsay, Esquire, avers that the facts set forth in the foregoing
instrument, based upon information and belief, were developed from conversations with Michael
Ross and information gained in the investigation of this file, and this Verification is made for the
reason that his Verification could not be obtained within the time allowed for the filing of this
pleading, and this Verification is made subject to the penalties of 18 Pa. C.S. §4904, relating to
unswom falsification to authorities.
FLOWER, FLOWER & LINDSAY, P.C.
By:
)D#34693
44-East High Street
Carlisle, PA 17013
(717) 243-5513
ross Complaint September 2, 1999
MICHAEL ROSS,
Plaintiff
VS.
MANUEL D. GOMEZ, ET UX,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
CERTIFICATE OF SERVICE
l
AND now, this -2i day of 1999, I, Carol J.
Lindsay, Esquire, of the law firm of FLOWER, FLOWER & INDSAY, P.C., Attorneys, hereby certify
that I served the within Plaintiffs Petition to Strike Appeal Untimely Filed and Counter-Claim
and Petition to Allow the Appeal Nunc Pro Tunc this day by depositing same in the United States
Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to:
Mr. and Mrs. Manuel D. Gomez
169 Lehman Drive
York, PA 17403
FLOWER, FLOWER & LINDSAY
Attorneys for Plaintiff
By:
,Carol J. Lindsay, Esquire
ID # 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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? 1999
V,
MICHAEL ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
Vs. CIVIL ACTION - LAW
NO. 99-4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant/Respondent
ORDER OF COURT
AND NOW this day of 1999, upon
consideration of the within Plaintiffs Petition to Strike Appeal Untimely Filed and Counter
Claim and Petition to Allow the Appeal Nunc Pro Tunc, Petition to Strike Appeal is dismissed.
By the Court,
iwi ? URIPIMIIL OUPLU UM) c, 1y
MICHAEL ROSS,
Plaintiff/Petitioner
f
Vs.
MANUEL D. GOMEZ, ET UX,
Defendant/Respondent
AND NOW this
day of
1999, upon
consideration of the within Plaintiffs Petition to Strike Appeal Untimely Filed and Counter
Claim and Petition to Allow the Appeal Nunc Pro Tunc, Petition to Strike Appeal is dismissed.
By the Court,
SEP - 3 1S9V
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
ORDER OF COURT
ross Complaint September 2, 1999
MICHAEL ROSS,
Plaintiff/Petitioner
Vs.
SEP - 3 iy?
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant/Respondent
ORDER OF COURT
AND NOW this
day of
1999, upon
consideration of the within Plaintiffs Petition to Strike Appeal Untimely Filed and Counter-
Claim and Petition to Allow the Appeal Nunc Pro Tunc, Petition to Strike Appeal is dismissed.
By the Court,
J.
MICHAEL ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA
' vs. CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
MANUEL D. GOMEZ, ET UX,
Defendant/Respondent
PLAINTIFF'S PETITION TO STRIKE
APPEAL UNTIMELY FILED
NOW comes MICHAEL ROSS, by and through his counsel, Flower, Flower & Lindsay,
P.C., and answers the Rule to Show Cause entered by the Court on August 9, 1999, as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Denied. By way of further answer, although the District Justice entered judgment
on May 15, 1999 as set out on the exhibit attached to the Petition, Notice of the judgment
transcript form was not sent by the District Justice's office until July 8, 1999 as noted on the Entry
of Judgment.
WHEREFORE, Petitioner prays this Honorable Court to Dismiss the Petition to Strike the
Appeal.
COUNTER-CLAIM AND
PETITION TO ALLOW THE APPEAL
NUNC PRO TUNC
5. Although the Judgment in the captioned case was entered on May 15, 1999, Notice
of the Judgment was not sent until July 8, 1999, on the specific request of counsel for the Plaintiff.
6. Rule 1002 of the Rules of Civil Procedure for District Justice's requires a Notice of
Judgment to be filed with an Appeal.
ross Complaint September 2, 1999
7. No Notice of Judgment was issued by the District Justice until July 9, 1999.
8. A Court may permit an Appeal Nunc Pro Tunc upon a showing of an error in the
f
judicial system.
9. The failure of the District Justice to mail the Notice of Judgment is such an error.
WHEREFORE, Plaintiff prays this Honorable Court to permit the Appeal Nunc Pro Tunc.
FLOWER, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
Carol rf Li dsay, Es
ID#446
11 East High Street
Carlisle, PA 17013
(717) 243-5513
rose Complaint September 2, 1999
VERIFICATION
1
The undersigned, Carol J. Lindsay, Esquire, avers that the facts set forth in the foregoing
instrument, based upon information and belief, were developed from conversations with Michael
Ross and information gained in the investigation of this file, and this Verification is made for the
reason that his Verification could not be obtained within the time allowed for the filing of this
pleading, and this Verification is made subject to the penalties of 18 Pa. C.S. §4904, relating to
unswom falsification to authorities.
FLOWER, FLOWER & LINDSAY, P.C.
By
Carlisle, PA 17013
(717) 243-5513
ross Complaint September 2, 1999
MICHAEL ROSS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
MANUEL D. GOMEZ, ET UX,
Defendant
CIVIL ACTION - LAW
NO. 99 - 4264 CIVIL TERM
CERTIFICATE OF SERVICE
AND now, this day of , 1999, I, Carol J.
Lindsay, Esquire, of the law firm of FLOWER, FLOWER & INDSAY, P.C., Attorneys, hereby certify
that I served the within Plaintiffs Petition to Strike Appeal Untimely Filed and Counter-Claim
and Petition to Allow the Appeal Nunc Pro Tunc this day by depositing same in the United States
Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to:
Mr. and Mrs. Manuel D. Gomez
169 Lehman Drive
York, PA 17403
FLOWER, FLOWER & LINDSAY
Attorneys for Plaintiff _
By:
ID J. Lindsay, E:
ID # 44693
11 East High Street
Carlisle, PA 17013
(717) 243-5513
4
LAW OFFICES
FLOWER, MORGENTHAL, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
11 EAST HIGH STREET
CARLISLE, PENNSYLVANIA 17013-3016
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CQ P88598566
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4569 MAILED FROM SARI;S(F w 17013
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George F. Douglas, III, Esquire
Douglas, Douglas & Douglas
27 West High Street
Carlisle, PA 17013
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LAW OFFICES
FLOWER, MORGENTHAL, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
11 EAST HIGH STREET
CARLISLE, PENNSYLVANIA 17013-3016
`AILS Hid,
4152500,33 8598566
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Carol J. Lindsay, Esquire
FLOWER, FLOWER & LINDSAY, P.C.
11 East High Street
Carlisle, PA 17013
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DOUGLAS, DOUGLAS & DOUGLAS George F. Douglas, III, Esquire.
27 W. HIGH ST. Supreme Court I.D.# 61886
POB 261
CARLISLE PA 17013
TELEPHONE 717-243-1790
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......................an... n- ..... Mrs................. M a..........nue(...........................................
Mr. d D. Gomez i In t e Court of Common Pleas of ?
Cumberland County, Pennsylvania
3 ?
f 1999 - No. 4264 Civil Term
3
Vs. i
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Michael Ross Civil Action Law
.......................................................................................................... i..........................................................................................................
Praecipe
TO THE PROTHONOTARY OF SAID COURT:
Please mark this case settled and discontinued.
Date: ?
August 7, 2000
George F. Douglas, III
Attorney for Plaintiff
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